ACCEPTED 15-25-00165-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 12/18/2025 10:59 AM No. 15-25-00165-CV CHRISTOPHER A. PRINE CLERK FILED IN IN THE FIFTEENTH COURT OF APPEALS 15th COURT OF APPEALS AUSTIN, TEXAS AUSTIN, TEXAS 12/18/2025 10:59:33 AM CHRISTOPHER A. PRINE Clerk Tap Rock Operating, LLC, Appellant, v. Texas Fabco Solutions, Inc., Appellee.

On Appeal from the 424th District Court, Blanco County, Texas Trial Court Cause No. CV09710 Hon. Evan Stubbs, Presiding

APPELLANT’S SECOND UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF

TO THE HONORABLE COURT OF APPEALS: Appellant Tap Rock Operating, LLC (“Appellant”) respectfully requests a 30-day extension to file its Appellant’s brief under Texas Rules of Appellate Procedure 10.5(b) and 38.6(d), and would respectfully show the Court as follows: Appellant’s brief is currently due on Monday, December 22, 2025. Appellant’s request an extension of 30-days from the current deadline, making Appellant’s brief due Wednesday, January 21, 2026.

See Tex. R. App. P. 4.1(a). This is Appellant’s second request for an extension of time for this deadline. Counsel for Appellees Texas Fabco Solutions, Inc. is unopposed to this motion.

The extension is necessary because counsel has had to devote time and attention, sometimes on an emergency basis, to the following matters: • Cause No. 2023-DCL-01534; Garcia, et al. v. Kommitted Transportation, Inc., et al.; in the 444th Judicial District Court of Cameron County, Texas; (prepared for and attended trial December 1, 2025); • Case No. 1-25-00751-CV; Jun Jin Heavy Industry, Co. Ltd., et al v. Epifanio Mondragon, et al; in the 215th Judicial District Court of Harris County, Texas; (Appellants’ brief deadline December 4, 2025); • Case No. 1:22-cv-00599-KG-JFR; Hurtado v. FNF Construction, Inc., et al.; in the United States District Court of New Mexico (prepared for and attended trial December 8, 2025); • Cause No. 23DCCV0902; Walter Harris v. Ellen May and Allstate Fire and Casualty Insurance Company; in the 136th Judicial District Court of Jefferson County, Texas; (attended hearing on defendant’s motion for new trial December 17, 2025); • Cause No. CV42105; Isaac Brooks v. Bruce Harold Johnson, Jr. and 3B Dozer Service, LLC; in the 82nd Judicial District Court of Falls County, Texas; (pre-trial motions due December 19, 2025 and trial set for January 5, 2026);

• Case No. 25-0503; In re Galen Wade Hudson; in the Supreme Court of Texas; (relator’s brief on the merits due December 22, 2025); • Cause No. 2025-86872; Amy Cherry v. Smyrna Ready Mix Concrete, LLC, et al.; in the 190th Judicial District Court of Harris County, Texas; (motion to transfer venue and answer due December 23, 2025); • Cause No. 92380-F; In the Interest of Rayyan Bhar and Ibrahim Bhar, Minor Children; in the 461st Judicial District Court of Brazoria County, Texas; (hearing on pre-trial motions set for January 7, 2026, prepare and attend trial set for January 12, 2026); • Cause No. DC-23-02975; Frankie Bakkers v. Energy Transfer, LP et al.; in the 68th Judicial District Court of Dallas County, Texas; (motion for new trial due January 9, 2026); • Cause No. 2022-70592; Casimira Lujano v. CWS Propane LLC; in the 184th Judicial District Court of Dallas County, Texas; (motion for summary judgment due January 11, 2026, prepare and attend trial set for February 16, 2026); and • Case No. 25-1097; Baird/Williams Construction II, Ltd. v. Jacinto Martinez; in the Supreme Court of Texas; (petition for review due January 14, 2026).

This extension is not sought for the purpose of delay; instead, it is sought to allow the preparation of concise and thorough brief that will assist in this Court’s consideration of the case before it.

PRAYER For the reasons stated herein, Appellant’s respectfully request that the Court issue an order extending the time for filing Appellant’s brief in this matter to January 21, 2026, and for all other and further relief to which Appellant’s may be entitled.

Respectfully submitted,

/s/ Heidi J. Gumienny Jessica Z. Barger State Bar No. 24032706 Heidi J. Gumienny State Bar No. 24036696 Maha Ghyas State Bar No. 24138115 WRIGHT CLOSE BARGER & GUZMAN, LLP One Riverway, Suite 2200 Houston, Texas 77056 (713) 572-4321 (Phone) (713) 572-4320 (Facsimile) [email protected] [email protected] [email protected] AND M. Matt Jett State Bar No. 24068684 Tim Redden, Jr. State Bar No. 24099654 HALL MAINES LUGRIN, PC 2800 Post Oak Blvd., Suite 6400 Houston, Texas 77056

(713) 871-9000 (Phone) (713) 871-8962 (Facsimile) [email protected] [email protected] COUNSEL FOR APPELLANT TAP ROCK OPERATING, LLC

CERTIFICATE OF CONFERENCE I hereby certify that Appellee’s counsel conferred with Appellant’s counsel regarding this Motion. Appellant is unopposed to the relief requested in this Motion.

/s/ Maha Ghyas Maha Ghyas

CERTIFICATE OF SERVICE I certify that a true and correct copy of the foregoing instrument was served on all counsel of record electronically through the electronic filing manager (www.efiletexas.gov) on this 18th day of December 2025.

/s/Heidi J. Gumienny Heidi J. Gumienny

Automated Certificate of eService This automated certificate of service was created by the efiling system.

The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.

Sandra Silva on behalf of Heidi Jean Gumienny Bar No. 24036696 [email protected] Envelope ID: 109252388 Filing Code Description: Motion Filing Description: 251218 Appellant's Second Unopposed Motion for Extension of Time to File Brief Status as of 12/18/2025 11:23 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jessica Z.Barger [email protected] 12/18/2025 10:59:33 AM SENT Heidi J.Gumienny [email protected] 12/18/2025 10:59:33 AM SENT Matt Jett [email protected] 12/18/2025 10:59:33 AM SENT Tim Redden, Jr. [email protected] 12/18/2025 10:59:33 AM SENT Larry D.Warren [email protected] 12/18/2025 10:59:33 AM SENT Maha Ghyas [email protected] 12/18/2025 10:59:33 AM SENT Sandra Silva [email protected] 12/18/2025 10:59:33 AM SENT